Professional Documents
Culture Documents
Confined Spaces: General Requirements
Confined Spaces: General Requirements
The Occupational Safety and Health Administration (OSHA) has not published
regulations dealing specifically with confined spaces found in the construction
industry. The OSHA confined-space standard, 29 CFR 1910.146, is written for
general industry and states that it is not applicable to construction. However, the
construction standard relating to safety training and education (29 CFR 1926.21)
places an affirmative duty on the employer to train employees who enter confined or
enclosed spaces during construction work on the hazards involved, precautions to
take, and protective and emergency equipment needed. Therefore, the general
industry standard on confined spaces still may be of use to roofing contractors as a
means of assessing and dealing with hazards and selecting proper personal
protective equipment (PPE) and emergency equipment. An OSHA training tool
addressing confined-space hazards in construction that also may be helpful follows
at the end of this chapter.
In roofing and waterproofing work, there are confined-space situations that pose
significant health and safety issues. For example, tankers and trenches provide an
enclosed atmosphere where hazards could exist for employees who enter. Tankers
can contain material residue that could be harmful, and gases and vapors can settle
in trenches and other low-lying areas, depleting oxygen or forming explosive
mixtures. Employees who enter those areas must be protected even though the
general industry confined-space rules do not apply to them. In addition,
lockout/tagout rules must be put into effect to secure the tanker from movement while
entry is made and work performed on the tanker’s interior.
General Requirements
OSHA requires roofing contractors to evaluate their workplaces to determine if any
spaces are to be classified as permit-required confined spaces. If permit-required
confined spaces are present, contractors must mark each entry point with a sign
reading “DANGER—PERMIT-REQUIRED CONFINED SPACE. DO NOT ENTER.”
When a roofing contractor determines that confined spaces exist, the next step is to
determine whether the confined space is a permit-required confined space. OSHA
defines a permit-required confined space as a confined space that meets one or
more of the following characteristics:
If one or more of these conditions exist, a contractor must follow the procedures
discussed under the paragraph in this chapter titled “Permit-required Confined Space
Requirements.”
Atmospheric Monitoring
It is impossible to detect a hazardous atmosphere without instruments designed for
that purpose. It should never be assumed that a confined space is safe or that an
employee will be fine if he or she doesn’t linger in a confined space or perform
dangerous work there. A person can be overcome in a hazardous atmosphere in a
matter of moments. Even quick and simple work in an area not recognized as a
confined space can result in injuries or death by asphyxiation or as a result of an
explosion.
In order to enter any confined space without the use of special types of PPE, such as
a self-contained breathing apparatus (SCBA), atmospheric conditions must have
these characteristics:
When testing for atmospheric hazards, a contractor should first test for oxygen.
Combustible gas meters are oxygen-dependent and will not work properly in an
oxygen-deficient atmosphere. Second, a contractor should test for combustible gases
and vapors because the threat of fire or explosion is usually more immediate and life-
threatening. Third, a contractor must test for toxic gases and vapors.
All the operations that will be taking place within the space and any hazardous
substances that may result, such as fumes from welding or vapors from solvents or
other chemicals, must be considered. The proximity to traffic and automotive vehicles
on site should also be noted because this may generate carbon monoxide.
If a hazardous atmosphere is detected at any time during the entry, the following are
required:
Once the contractor satisfies the requirements for entering using alternative entry
procedures, certification must be completed before anyone enters the confined
space. The certification consists of the date, location of the space and signature of
the person providing the certification.
A contractor must verify these conditions are met through certification, which is the
same as the alternative entry procedure. Again, the date, location of the space and
name of the person certifying the space must be on the certificate. This certificate
must be made available to employees before entering the space.
If hazards arise in a confined space that has been declassified, each employee must
exit the space. The contractor must determine if the space needs to be reclassified
as a permit-required confined space. If the hazards are eliminated, the nonpermit
entry can continue.
It is important to note that the difference between an alternative entry procedure and
a nonpermit-required confined space is the use of forced-air ventilation. If forced-air
ventilation is used during an entry, it cannot be classified as a nonpermit-required
confined space. It must be classified as an alternative entry procedure.
It is in the best interest of the contractor to try to meet the requirements of alternative
entry procedures or nonpermit-required confined spaces because the requirements
for the two are much less stringent than for a permit-required confined space.
However, it imposes the burden of making certain the conditions inside the space do
not change.
– Gas-detection equipment
– Ventilating equipment
– Communication equipment if necessary
– PPE to be used when engineering controls such as ventilation
equipment is not practical
– Lighting
– Barricades to prevent unauthorized entry
– Equipment, such as ladders, to provide for safe access to and egress
from the permit space
– Rescue and emergency equipment, unless this service is provided
– Any other equipment that would be used for safe permit space entry
Evaluation of permit space conditions during entry operations by:
Provision of at least one attendant outside the permit space (an explanation of
duties and training requirements of the attendant follows)
Designation of employees who have active roles in entry operations and
identification of the training requirements for those employees
Development and implementation of procedures for summoning rescue and
emergency services
Development of a permit system to include preparation, issuance, use and
cancellation of permits
Coordination of entry operations when more than one employer is involved
Cancellation of a permit after the work is complete
Review of entry operations to correct problems that may have occurred during
the entry operation
Review of the written program annually, making revisions as needed
Permit System
As stated before, OSHA requires employers to develop and implement a permit
system. This system will ensure all steps have been taken to protect employees from
hazards that may be in a confined space. Two sample permits are included at the
end of this chapter.
Entry supervisors are required to sign the completed permit, authorizing the permit
operations to begin. Authorized entrants must have the opportunity to review the
permit before they enter the permit space. Also, a copy of the permit must be posted
at the entry point of the space.
An estimated time for an entry operation must be provided on the permit. Once the
time has expired, the permit is canceled and the operation must cease. In addition,
the entry supervisor must cancel the entry when the operation is complete or when a
condition arises in the space that was not allowed under the original permit
conditions. Unpermitted conditions must be noted on the entry permit.
The permit must be retained for one year so it can be reviewed when the written
program is reviewed.
Training
OSHA requires contractors to provide training for those who may be involved in the
permit-required confined-space process. Training must be conducted before
employees are first assigned duties relating to confined spaces or if there is a change
in their assignments. Training must also be conducted when new hazards arise
relating to permit-space operations where employees have not received prior
training. Also, training must be provided to each affected employee whenever the
contractor believes there are deviations from the permit-space entry.
Contractors must train their employees so they are proficient in the duties of an
authorized entrant, attendant or entry supervisor. All training must be certified,
indicating employees’ names, trainers’ signatures or initials, and dates of training.
Authorized Entrants
Authorized entrants are employees who have been trained and approved to enter a
confined space. These employees must have had training regarding the potential
hazards of the confined space, as well as the signs and symptoms of overexposure
to any of the hazards. They should be familiar with all equipment, know if the
equipment is explosion-proof, and know how to tell when it is properly grounded.
Authorized entrants must know how to communicate with the attendant, especially if
a prohibited condition or a hazardous situation arises. Entrants must agree to exit
immediately if an order is given to do so or an alarm goes off. Entrants must wear
full-body harnesses with retrieval lines attached to the center of their backs or above
their heads or wristlets if full-body harnesses are shown to be infeasible.
Authorized Attendants
Authorized attendants must be able to monitor situations inside and outside confined
spaces so they can order entrants to evacuate a space if a dangerous situation
arises in either place. Attendants must be well aware of the hazards of the confined
space and also aware of the physical and behavioral effects of hazard exposure so
that they would notice the effects in any of the entrants. If an emergency situation
arises in the confined space, the attendant is the person responsible for summoning
emergency services and performing whatever rescue operation he or she has been
trained and equipped to perform. Another responsibility is keeping all unauthorized
entrants out of the confined space. Under no circumstances is an attendant permitted
to leave the space until replaced by another attendant or all entrants have come out
of the space.
Entry Supervisors
Entry supervisors must know the hazards of confined spaces and the signs and
symptoms of overexposure to those hazards. They must verify that permits are filled
in, the appropriate testing and procedures have been completed, and all equipment
is in place. The supervisor is the person responsible for knowing when and under
what conditions to cancel a permit and terminate the work. Supervisors must also
remove unauthorized persons. Finally, they are responsible for making sure rescue
services are available and the means for calling them are operable.
Training for in-house rescue services requires employees to be trained in the rescue
gear they would need to extract someone from a confined space. Because the
rescuers need to enter the permit space, they must also receive the same level of
training that authorized entrants receive. Once every 12 months, rescuers must
simulate an actual rescue using real people or mannequins. At least one member of
the in-house rescue team must be trained in first aid/CPR.
The second option, summoning an outside rescue team to perform the rescue, is a
more difficult option with which to comply. A contractor must evaluate the prospective
rescue team to determine how quickly it is capable of responding after members.
OSHA requires the rescue team to respond in a timely manner, consistent with the
specific hazard in the confined space.
The contractor must select a rescue team that has the capability to reach any victim
within a time frame that is appropriate for the hazard in the permit space. The rescue
team must be proficient in performing the needed rescue service. The contractor
must also inform the rescue team of all types of permit-required confined spaces they
have and give them time to practice and develop rescue plans.
The last option is to provide nonentry rescues. If this option is selected, the person
entering the confined space must wear a full-body harness with a retrieval line
attached to it. The retrieval line must be attached to a mechanical device, such as a
tripod and winch or a fixed point outside the permit space. This will allow someone to
pull an incapacitated victim out of the confined space.
Material safety data sheets (MSDSs) for chemicals to which an entrant was exposed
in a confined space are required to be made available to the medical facility that
provides aid.
Sample Written Program
Introduction
This program identifies specific responsibilities of different parties and presents the
criteria required for safe entry into permit-required confined spaces.
Definitions
confined space: A space that has limited or restricted means of entry, is not designed
for continuous occupancy, and is large enough and configured so that a person can
enter the space and maneuver well enough to perform tasks.
permit-required confined space: A confined space that has the potential to expose
personnel to hazards that require controls to prevent injury or death. These hazards
may include any or all of the following:
Hazardous atmospheres
nonpermit-required confined space: A confined space that does not have the
potential for containing atmospheric conditions capable of causing injury or death.
General Procedures
Based on these definitions, management is responsible for determining
which areas are considered confined spaces and which confined
spaces are permit-required confined spaces.
It is also important that employees fully understand the roles and training
requirements of attendants, entrants and entry supervisors.
Upon completion of training, [company name] will issue certificates indicating each
employee’s name and identification number, such as social security number; dates of
training; and name of the trainer.
Ensure the entry permit is completely and properly filled out and verify
that the air monitoring has been done correctly.
Know the evacuation signal, and understand that the attendant can
initiate immediate evacuations requiring all entrants to exit.
Monitor activities inside and outside the confined space to ensure the
safety of the entrants.
Permit System
Prior to confined space entry, the permit must be filled out completely.
The entry supervisor must sign the permit before personnel enter the
permit-required confined space.
The completed permit must be posted at the entry point of the confined
space so entrants can review it and confirm that the pre-entry steps
have been taken.
The permit is only valid for the duration of the work performed.
Work is complete
Conditions arise that were not accounted for on the original
permit
After the completion of the entry, the permit will be retained for a period
of one year to facilitate review of the PRCS program. Any problems
encountered during the entry must be noted on the permit and used for
review.
Atmospheric Monitoring
Before an employee enters any confined space, atmospheric testing
will be conducted to assess the ambient conditions inside the space.
The devices must be equipped with audio alarms, visual alarms or both.
If levels rise above or fall below the required ranges while employees
are in the confined space, the entry will be terminated and the attendant
will instruct all employees to evacuate the space.
If the confined space has a height of more than 5 feet with an entry
point overhead, each entrant will be required to wear a body harness
attached to a mechanical retrieval system, such as a tripod.
If the confined space is less than 5 feet in height but has a potentially
hazardous atmosphere, each entrant will wear a body harness attached
to a lifeline that will be monitored by the attendant. This system will
allow the attendant to perform a non-entry rescue, if necessary, by
pulling the entrant out by the lifeline.
If the confined space entry requires more than one entrant using an
airline system, the attendant will be responsible for ensuring the air
hoses and lifelines do not become entangled.
Training must take place initially before confined space entries occur
and annually thereafter. Each rescue team member must practice
removing humans or life-size mannequins.
Each team member must be trained in first aid. At least one member
must be trained in first aid and CPR.
If an emergency occurs and these conditions are not satisfied, an attendant will call
the fire department or the specified rescue service. If [company name] elects to use
an outside organization to perform rescue duties, it will:
All data from items 1 and 2 are recorded and made available for all
entrants to review.
If the items can be achieved and the space reclassified, the following procedures will
be implemented:
Any condition making it unsafe to remove an entrance cover will be
eliminated before the cover is removed.
After entrance covers are removed, guardrails, barricade tape, etc., will
be erected to prevent accidental falls through the opening.
The use of forced-air ventilation systems does not constitute the elimination of
atmospheric hazards during nonpermit-required confined space entries.
EMERGENCY SERVICE
Name of Service Phone Number Method of Contact
___________________ ___________________ __________________
___________________ ___________________ __________________
Isolation Methods:
Personal Awareness:
-entry briefing on specific hazards and control methods
about permit and hazard conditions
TESTING RECORD
Time Oxygen-min.Oxygen-max Flammability H2S Toxic CI2 CO SO2 Heat Other Tester
Acceptable (specify) Initials
Conditions >19.5% <23.5% <10% LEL/LFL <10ppm <0.5ppm <35ppm <2ppm °F/°C
Result _________ __________ ___________ ______ _________ ______ _______ ______ ______ ______ _______
a.m./p.m.
Result _________ __________ ___________ ______ _________ ______ _______ ______ ______ ______ _______
a.m./p.m.
Result _________ __________ ___________ ______ _________ ______ _______ ______ ______ ______ _______
a.m./p.m.
Result _________ __________ ___________ ______ _________ ______ _______ ______ ______ ______ _______
a.m./p.m.
Result _________ __________ ___________ ______ _________ ______ _______ ______ ______ ______ _______
a.m./p.m.
Result _________ __________ ___________ ______ _________ ______ _______ ______ ______ ______ _______
a.m./p.m.
Result _________ __________ ___________ ______ _________ ______ _______ ______ ______ ______ _______
a.m./p.m.
______________________________ _____________________________
______________________________ _____________________________
______________________________ _____________________________
______________________________ _____________________________
______________________________ _____________________________
______________________________ _____________________________
______________________________ _____________________________
______________________________ _____________________________
______________________________ _____________________________
______________________________ _____________________________
______________________________ _____________________________
______________________________ _____________________________
Construction Safety and Health U.S. Department of Labor
OSHA Office of Training and Education
Outreach Program May 1996
THE ISSUE
Fatalities and injuries constantly occur among construction workers who, during the course of their jobs, are required to enter confined
spaces. In some circumstances, these workers are exposed to multiple hazards, any of which may cause bodily injury, illness, or death.
Newspaper and magazine articles abound with stories of workers injured and killed from a variety of atmospheric factors and physical
agents. Throughout the construction jobsite, contractors and workers encounter both inherent and induced hazards within confined
workspaces.
INHERENT HAZARDS
Inherent hazards, such as electrical, thermal, chemical, mechanical, etc., are associated with specific types of equipment and the
interactions among them. Examples include high voltage (shock or corona discharge and the resulting burns), radiation generated by
equipment, defective design, omission of protective features (no provision for grounding non-current-carrying conductive parts), high or
low temperatures, high noise levels, and high-pressure vessels and lines (rupturing with resultant release of fragments, fluids, gases,
etc.). Inherent hazards usually cannot be eliminated without degrading the system or equipment, or without making them inoperative.
Therefore, emphasis must be placed on hazard control methods.
INDUCED HAZARDS
Induced hazards arise and are induced from a multitude of incorrect decisions and actions that occur during the actual construction
process. Some examples are: omission of protective features, physical arrangements that may cause unintentional worker contact with
electrical energy sources, oxygen-deficient atmospheres created at the bottom of pits or shafts, lack of safety factors in structural
strength, and flammable atmospheres.
Following are typical examples of confined workspaces in construction which contain both inherent and induced hazards.
Vaults
A variety of vaults are found on the construction jobsite. On various occasions, workers must enter these vaults to perform a number of
functions. The restricted nature of vaults and their frequently below-grade location can create an assortment of safety and health
problems.
Oxygen-Deficient Atmosphere
One of the major problems confronting construction workers while working in vaults is the ever-present possibility of an oxygen-deficient
atmosphere.
While working in an electrical vault, workers may be exposed to the build-up of explosive gases such as those used for heating
(propane). Welding and soldering produce toxic fumes which are confined in the limited atmosphere.
Electrical Shock
Electrical shock is often encountered from power tools, line cords, etc. In many instances, such electrical shock results from the fact that
the contractor has not provided an approved grounding system or the protection afforded by ground-fault circuit interrupters or low-
voltage systems.
Purging
In some instances, purging agents such as nitrogen and argon may enter the vault from areas adjacent to it. These agents may displace
the oxygen in the vault to the extent that it will asphyxiate workers almost immediately.
A hazard normally considered a problem associated with confined spaces is material or equipment which may fall into the vault or onto
workers as they enter and leave the vault. Vibration could cause the materials on top of the vault to roll off and strike workers. If the
manhole covers were removed, or if they were not installed in the first place, materials could fall into the vault, causing injury to the
workers inside.
Condenser Pits
A common confined space found in the construction of nuclear power plants is the condenser pit. Because of their large size, they are
often overlooked as potentially hazardous confined spaces. These below-grade areas create large containment areas for the
accumulation of toxic fumes, gases, and so forth, or for the creation of oxygen-deficient atmospheres when purging with argon, freon, and
other inert gases. Other hazards will be created by workers above dropping equipment, tools, and materials into the pit.
Manholes
Throughout the construction site, manholes are commonplace. As means of entry into and exit from vaults, tanks, pits, and so forth,
manholes perform a necessary function. However, these confined spaces may present serious hazards which could cause injuries and
fatalities. A variety of hazards are associated with manholes. To begin with, the manhole could be a dangerous trap into which the worker
could fall. Often covers are removed and not replaced, or else they are not provided in the first place.
Pipe Assemblies
One of the most frequently unrecognized types of confined spaces encountered throughout the construction site is the pipe assembly.
Piping of sixteen to thirty-six inches in diameter is commonly used for a variety of purposes. For any number of reasons, workers will
enter the pipe. Once inside, they are faced with potential oxygen-deficient atmospheres, often caused by purging with argon or another
inert gas. Welding fumes generated by the worker in the pipe, or by other workers operating outside the pipe at either end, subject the
worker to toxic atmospheres. The generally restricted dimensions of the pipe provide little room for the workers to move about and gain
any degree of comfort while performing their tasks. Once inside the pipe, communication is extremely difficult. In situations where the
pipe bends, communication and extrication become even more difficult. Electrical shock is another problem to which the worker is
exposed. Ungrounded tools and equipment or inadequate line cords are some of the causes. As well, heat within the pipe run may cause
the worker to suffer heat prostration.
Ventilation Ducts
Ventilation ducts, like pipe runs, are very common at the construction site. These sheet metal enclosures create a complex network which
moves heated and cooled air and exhaust fumes to desired locations in the plant. Ventilation ducts may require that workers enter them
to cut out access holes, install essential parts of the duct, etc. Depending on where these ducts are located, oxygen deficiency could
exist. They usually possess many bends, which create difficult entry and exit and which also make it difficult for workers inside the duct to
communicate with those outside it. Electrical shock hazards and heat stress are other problems associated with work inside ventilation
ducts.
Tanks
Tanks are another type of confined workspace commonly found in construction. They are used for a variety of purposes, including the
storage of water, chemicals, etc.
Tanks require entry for cleaning and repairs. Ventilation is always a problem. Oxygen-deficient atmospheres, along with toxic and
explosive atmospheres created by the substances stored in the tanks, present hazards to workers. Heat, another problem in tanks, may
cause heat prostration, particularly on a hot day. Since electrical line cords are often taken into the tank, the hazard of electrical shock is
always present. The nature of the tank's structure often dictates that workers must climb ladders to reach high places on the walls of the
tank.
Sumps
Sumps are commonplace. They are used as collection places for water and other liquids. Workers entering sumps may encounter an
oxygen-deficient atmosphere. Also, because of the wet nature of the sump, electrical shock hazards are present when power tools are
used inside. Sumps are often poorly illuminated. Inadequate lighting may create an accident situation.
Containment Cavities
These large below-grade areas are characterized by little or no air movement. Ventilation is always a problem. In addition, the possibility
of oxygen deficiency exists. As well, welding and other gases may easily collect in these areas, creating toxic atmospheres. As these
structures near completion, more confined spaces will exist as rooms are built off the existing structure.
Electrical Transformers
Electrical transformers are located on the jobsite. They often contain a nitrogen purge or dry air. Before they are opened, they must be
well vented by having air pumped in. Workers, particularly electricians and power plant operators, will enter these transformers through
hatches on top for various work-related reasons. Testing for oxygen deficiency and for toxic atmospheres is mandatory.
Heat Sinks
These larger pit areas hold cooling water in the event that there is a problem with the pumps located at the water supply to the plant--
normally a river or lake--which would prevent cooling water from reaching the reactor core. When in the pits, workers are exposed to
welding fumes and electrical hazards, particularly because water accumulates in the bottom of the sink. Generally, it is difficult to
communicate with workers in the heat sink, because the rebar in the walls of the structure deaden radio signals.
UNUSUAL CONDITIONS
By the very nature of construction, situations are created which illustrate one of the most hazardous confined spaces of all--a confined
space within a confined space. This situation appears as tanks within pits, pipe assemblies or vessels within pits, etc. In this situation, not
only do the potential hazards associated with the outer confined space require testing, monitoring, and control, but those of the inner
space also require similar procedures. Often, only the outer space is evaluated. When workers enter the inner space, they are faced with
potentially hazardous conditions. A good example of a confined space within a confined space is a vessel with a nitrogen purge inside a
filtering water access pit. Workers entering the pit and/or the vessel should do so only after both spaces have been evaluated and proper
control measures established.
During an examination of confined spaces in construction, one often encounters situations which are not always easy to evaluate or
control. For instance, a room or area which classifies as a confined space may be relatively safe for work. However, access passages
from other areas outside or adjacent to the room could, at some point, allow the transfer of hazardous agents into the "safe" one. One
such instance would be a pipe coming through a wall into a containment room. Welding fumes and other toxic materials generated in one
room may easily travel through the pipe into another area, causing it to change from a safe to an unsafe workplace. A serious problem
with a situation such as this is that workers working in the "safe" area are not aware of the hazards leaking into their area. Thus, they are
not prepared to take action to avoid or control it.
CONCLUSION
In this discussion, we have defined inherent and induced hazards in confined spaces. We have examined typical confined spaces on
construction sites and we have described representative hazards within these confined spaces.